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PRIVACY NOTICE

This document constitutes the Privacy Notice for the purposes set forth in the Federal Law on the Protection of Personal Data Held by Private Parties (the “LFPDP”) and the provisions arising from or related to it. This Privacy Notice (hereinafter the “Notice”) applies to the personal information collected about the Data Subject by Grupo IBC, Intermediary Business Consulting, IBC, in its capacity as Controller.

At Grupo IBC, Intermediary Business Consulting, with address at Av. Empresarios 255, Torre Icon 23, Puerta de Hierro CP. 45116 Zapopan, Jalisco, Mexico, we are aware that you have the right to know what information we collect about you and our practices regarding such information. The conditions set forth herein apply to all information collected on behalf of Desarrollo Integral de Productos y Servicios S.A. de C.V. (hereinafter “THE CONTROLLER”).

For the purposes of this Notice, any terms used herein that are not defined in it shall have the meaning attributed to them in the LFPDP. The purpose of this Notice is to establish the terms and conditions under which “THE CONTROLLER” (or the Processor designated by “THE CONTROLLER”):

  • Will receive and protect the Data Subject's Personal Data in order to protect their privacy and their right to informational self-determination.

Will receive and protect the Data Subject's Personal Data in order to protect their privacy and their right to informational self-determination.

  • Will use the Data Subject's Personal Data.

Will use the Data Subject's Personal Data.

  • Will, where applicable, carry out transfers of Personal Data to third parties.

Will, where applicable, carry out transfers of Personal Data to third parties.

Personal Data collected:

The Controller” may process Personal Data, that is, information that identifies you or makes you identifiable. Some of this personal data includes, for example: name, gender, email address, mailing address, residential address, document identification number, date of birth, payment data (such as credit card number and expiration date), billing data, date of birth, landline and/or mobile phone number, Federal Taxpayer Registry (RFC), card and/or account numbers, asset and financial information, among others. You provide this personal data voluntarily when you decide to be given information and requirements about the products and/or services that “The Controller” offers.

“The Controller” may cross-reference the information you provide with other information you have voluntarily provided to third parties. This is done in order to tailor our products, services and promotions to your preferences. The collection of personal data may take place, for example:

  • Through the use of emails and visits to our offices.

Through the use of emails and visits to our offices.

  • When you contact us by telephone.

When you contact us by telephone.

  • Through the use of the Controller's websites.

Through the use of the Controller's websites.

  • Through the voluntary submission of information via the dialog windows enabled on the sites.

Through the voluntary submission of information via the dialog windows enabled on the sites.

  • Through the use of automatic data capture tools.

Through the use of automatic data capture tools.

  • Through publicly accessible sources and other sources available in the market.

Through publicly accessible sources and other sources available in the market.

“The Controller” may also collect Personal Data from publicly accessible sources and other sources available in the market to which the Data Subject may have given consent to share their personal information, or that may have provided anonymous demographic information associated with a given geographic area.

Likewise, the documentation that may be collected by “THE CONTROLLER” to verify the identity of the Data Subject includes: voter ID card, discharged national military service identity booklet, RFC registration certificate, CURP registration certificate, proof of address, the special credit report issued by a Credit Information Company, asset relationships, marital status, family relationships, among others.

In the case of job applicants, the following may also be requested, among others: birth certificate, proof of education, the account statement from the Retirement Fund Administrator (Afore), the tax withholding statement, as well as the psychometric, medical and socioeconomic assessments conducted by “The Controller”.

You may also be asked for the Personal Data of your family members, dependents or beneficiaries and the relevant supporting documentation.

Uses and purposes of your personal data

The Personal Data you provide to “THE CONTROLLER” will be processed, in addition to fulfilling the obligations arising from any relationship that may be created with you, for the following purposes:

  • To provide you with information about products, services or other activities or proposals of interest from “THE CONTROLLER” and its subsidiaries, affiliates and parent company.

To provide you with information about products, services or other activities or proposals of interest from “THE CONTROLLER” and its subsidiaries, affiliates and parent company.

  • We use the information we collect to provide you with the products and/or services you request, and to inform you about other products and services offered by “THE CONTROLLER” to the user.

We use the information we collect to provide you with the products and/or services you request, and to inform you about other products and services offered by “THE CONTROLLER” to the user.

  • We use the information we collect to provide you with the products and/or services you request, and to inform you about other products and services offered by “THE CONTROLLER” to the user. Such third parties are obligated to maintain the confidentiality of the personal data provided and to comply with this Privacy Notice.

We use the information we collect to provide you with the products and/or services you request, and to inform you about other products and services offered by “THE CONTROLLER” to the user. Such third parties are obligated to maintain the confidentiality of the personal data provided and to comply with this Privacy Notice.

  • The user authorizes their personal data to be transmitted or supplied to other financial institutions, unless they express their objection through any of the means the Controller makes available.

The user authorizes their personal data to be transmitted or supplied to other financial institutions, unless they express their objection through any of the means the Controller makes available.

  • To ask you to respond to satisfaction surveys regarding our products and/or services.

To ask you to respond to satisfaction surveys regarding our products and/or services.

  • To contact you regarding the result of the evaluations or analysis of your credit application, with respect to the products and/or services offered by “THE CONTROLLER” or any other matter related to your application.

To contact you regarding the result of the evaluations or analysis of your credit application, with respect to the products and/or services offered by “THE CONTROLLER” or any other matter related to your application.

  • To follow up on any issue that may have arisen regarding the products and/or services offered by “THE CONTROLLER”.

To follow up on any issue that may have arisen regarding the products and/or services offered by “THE CONTROLLER”.

  • Where applicable, to verify the Data Subject's creditworthiness and/or ability to pay, which may be done through credit information companies, in accordance with the Law Regulating Credit Information Companies.

Where applicable, to verify the Data Subject's creditworthiness and/or ability to pay, which may be done through credit information companies, in accordance with the Law Regulating Credit Information Companies.

  • In general, to send you information from “THE CONTROLLER” and its subsidiaries, affiliates and parent company, for advertising and promotional purposes.

In general, to send you information from “THE CONTROLLER” and its subsidiaries, affiliates and parent company, for advertising and promotional purposes.

If your personal data is intended to be used for a purpose other than those above, “THE CONTROLLER” will notify you by email or telephone in order to obtain your consent to process your personal data for the new purposes. If consent is not received in cases where it is required, “THE CONTROLLER” will not use your personal data.

In the case of job applicants of “THE CONTROLLER”, the following activities will be carried out:

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  • Carrying out the recruitment and personnel selection process.

Carrying out the recruitment and personnel selection process.

  • Carrying out the hiring process. “THE CONTROLLER” will safeguard the information obtained from applicants as well as that of its employees, consisting of their Personal Data, profession, address, among others, for storage, authentication and validation of information. The information submitted by applicants for a vacancy will, where applicable, be safeguarded by “THE CONTROLLER”. If the applicant requests that their information be returned, “THE CONTROLLER”, through its established processes, will return the respective information.

Carrying out the hiring process. “THE CONTROLLER” will safeguard the information obtained from applicants as well as that of its employees, consisting of their Personal Data, profession, address, among others, for storage, authentication and validation of information. The information submitted by applicants for a vacancy will, where applicable, be safeguarded by “THE CONTROLLER”. If the applicant requests that their information be returned, “THE CONTROLLER”, through its established processes, will return the respective information.

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Data collection when browsing the websites and web pages of “THE CONTROLLER”

The automatic data capture tools used by “THE CONTROLLER” on its websites and web pages include cookies, web beacons and links in emails.

Use of Cookies.- The proper functioning of “THE CONTROLLER's” sites requires “cookies” to be enabled in your Internet browser. “Cookies” are small data files transferred by the website to your computer's hard drive when you browse the site. Cookies may be session-based or permanent.

Session cookies do not remain on your computer after you close your browser session, whereas permanent cookies remain on computers until they are deleted or expire. In most browsers, cookies are accepted.

Automatically, by virtue of its default configuration. You can adjust your browser preferences to accept or reject cookies. Disabling cookies may impair various functions of “THE CONTROLLER's” websites or prevent them from displaying correctly. If you prefer to delete the information from the cookies sent by “THE CONTROLLER”, you may delete the file(s) at the end of each browser session. Relevant information can be found on the sites of the major Internet browsers.

Links in “THE CONTROLLER's” emails.- Emails may include links that allow “THE CONTROLLER” to know whether you activated the link and visited the destination web page, and this information may be included in your profile. If you prefer that “THE CONTROLLER” not collect information about your interaction with such links, you may choose to change the format of “THE CONTROLLER's” communications (for example, receiving the message in text format rather than HTML format) or you may disregard the link and not access its content. “THE CONTROLLER's” emails may include links designed to direct you to the relevant sections of the websites, redirecting you through “THE CONTROLLER's” servers.

“THE CONTROLLER” will not share your personal data with third parties, domestic or foreign, outside the group of companies and affiliates of “THE CONTROLLER” without your prior consent, except that:

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  • The law or a court order so requires.

The law or a court order so requires.

  • To protect the rights or property of “THE CONTROLLER” or its clients.

To protect the rights or property of “THE CONTROLLER” or its clients.

  • Where such transfer is provided for in the Federal Law on the Protection of Personal Data Held by Private Parties.

Where such transfer is provided for in the Federal Law on the Protection of Personal Data Held by Private Parties.

By having read, understood and agreed to the terms set forth in this Notice, the Data Subject consents to “THE CONTROLLER”, or any Processor, carrying out transfers of Personal Data to domestic or foreign third parties, on the understanding that the processing such third parties give to the Data Subject's Personal Data must comply with the provisions of this Notice.

“THE CONTROLLER” may transfer your Personal Data to other third parties that support it in fulfilling the contracts or legal relationships it has with the Data Subject.

The Data Subject acknowledges and accepts that the Controller does not require authorization or confirmation from said Data Subject to carry out domestic or international transfers of Personal Data in the cases provided for in Article 37 of the LFPDP or in any other exception provided for by it or other applicable legislation.

Security

“THE CONTROLLER” has adopted the administrative, technical and physical security measures necessary to protect your personal data against damage, loss, alteration, destruction or unauthorized use, access or processing. However, “THE CONTROLLER” cannot, and therefore does not, guarantee that there will be no unauthorized access to your personal data or that communications will be free from any interruption, error or interception by unauthorized third parties.

Access to your personal data held by “THE CONTROLLER” will be limited to those persons who need access to such information for the purpose of carrying out the identified purposes.

If, when providing your Personal Data to “THE CONTROLLER”, you are assigned a username and password, you will be responsible for keeping such information confidential. We suggest that you not share this information with anyone. If you share your device, always be sure to log out before leaving a site or service in order to prevent unauthorized third parties from accessing your information.

The Data Subject's Personal Data collected by “THE CONTROLLER” and/or its Processors will be protected by appropriate administrative, technical and physical security measures against damage, loss, alteration, destruction or unauthorized use, access or processing, in accordance with the provisions of the LFPDP and the administrative regulations derived from it.

Rights that correspond to You as the owner of personal data. You may request from the Personal Data Protection Department of “THE CONTROLLER” the access, rectification, cancellation or objection (ARCO rights) regarding your personal data.

The ARCO Rights are as follows:

  • Access.- To be informed which of your personal data is contained in the databases of “THE CONTROLLER” and for what purpose such personal data is used, the origin of such data and the communications that have been made with it.

Access.- To be informed which of your personal data is contained in the databases of “THE CONTROLLER” and for what purpose such personal data is used, the origin of such data and the communications that have been made with it.

  • Rectification.- To have your personal data corrected or updated in the event that it is inaccurate or incomplete. You must inform “THE CONTROLLER” of the changes that should be made to your personal data when such changes are known only to you.

Rectification.- To have your personal data corrected or updated in the event that it is inaccurate or incomplete. You must inform “THE CONTROLLER” of the changes that should be made to your personal data when such changes are known only to you.

  • Cancellation.- To have your personal data removed, in whole or in part, from the databases of “THE CONTROLLER”. This request will give rise to a blocking period, after which the data will be deleted. There are cases in which cancellation will not be possible under the terms of the Federal Law on the Protection of Personal Data Held by Private Parties and other applicable legal provisions.

Cancellation.- To have your personal data removed, in whole or in part, from the databases of “THE CONTROLLER”. This request will give rise to a blocking period, after which the data will be deleted. There are cases in which cancellation will not be possible under the terms of the Federal Law on the Protection of Personal Data Held by Private Parties and other applicable legal provisions.

  • Objection.- To object, for legitimate cause, to the processing of your personal data by “THE CONTROLLER” or to limit its use or disclosure. In cases where the objection may relate to the receipt of certain communications, such communications will include the option to opt out of the mailing list and stop receiving them.

Objection.- To object, for legitimate cause, to the processing of your personal data by “THE CONTROLLER” or to limit its use or disclosure. In cases where the objection may relate to the receipt of certain communications, such communications will include the option to opt out of the mailing list and stop receiving them.

You have, at all times, the right to access, rectify and cancel your personal data, as well as to object to its processing or revoke the consent you have provided for that purpose, by submitting a request with the following information and documentation:

  • The Data Subject's name and address or another means by which to communicate the response to your request.

The Data Subject's name and address or another means by which to communicate the response to your request.

  • Documents that prove your identity (a plain copy in printed or electronic format of your voter ID card, passport or FM-3) or, where applicable, the legal representation of the Data Subject (a plain copy in printed or electronic format of the simple power of attorney bearing the handwritten signature of the Data Subject and the attorney-in-fact, along with their respective official identifications: voter ID card, passport or FM-3);

Documents that prove your identity (a plain copy in printed or electronic format of your voter ID card, passport or FM-3) or, where applicable, the legal representation of the Data Subject (a plain copy in printed or electronic format of the simple power of attorney bearing the handwritten signature of the Data Subject and the attorney-in-fact, along with their respective official identifications: voter ID card, passport or FM-3);

  • A clear and precise description of the Personal Data in respect of which you seek to exercise any of the ARCO Rights.

A clear and precise description of the Personal Data in respect of which you seek to exercise any of the ARCO Rights.

  • Any other element or document that facilitates locating the Data Subject's Personal Data.

Any other element or document that facilitates locating the Data Subject's Personal Data.

  • In the case of requests to rectify Personal Data, the respective Data Subject must also indicate the modifications to be made and provide documentation supporting their request.

In the case of requests to rectify Personal Data, the respective Data Subject must also indicate the modifications to be made and provide documentation supporting their request.

The Controller or its Processors will respond to the respective Data Subject within a maximum period of ten business days, counted from the date the request was received. The aforementioned periods may be extended only under the terms of the LFPDP.

The delivery of Personal Data will be free of charge; you will only be responsible for covering justified shipping costs or the cost of reproduction in copies or other formats. For purposes of requests to cancel Personal Data, in addition to the provisions of this Notice, the provisions of Article 26 of the LFPDP will apply, including the exceptions to the cancellation of Personal Data set forth therein.

The submission of a request to object to the use of Personal Data by the Data Subject thereof will give “THE CONTROLLER” the authority to object to the use of the Personal Data that the Data Subject has provided to the objecting party.

Consent

For the purposes of the provisions of the LFPDP, and in particular Article 17 thereof, the Data Subject states:

That this Notice has been made known to them by “THE CONTROLLER”.

That they have read, understood and agreed to the terms set forth in this Notice, and therefore grant their consent to the processing of their Personal Data for the purposes of the LFPDP and other applicable legislation. In the event that the Personal Data collected includes sensitive or financial Personal Data, by signing the corresponding contract, whether in printed format or using electronic means and their corresponding processes for forming consent—for example, by way of illustration and not limitation, by providing Personal Data through dialog windows, or by viewing and scrolling through terms and conditions on screen—acts will be carried out that constitute the express consent of the data subject under the terms of the second paragraph of Article 8 of the LFPDP and other applicable legislation.

That they grant their consent for “THE CONTROLLER” or its Processors to carry out transfers of Personal Data to domestic or foreign third parties, on the understanding that the processing such third parties give to their Personal Data must comply with the provisions of this Notice.

If the Data Subject does not object to the terms of the Notice, its content will be deemed agreed and consented to, under the terms of the third paragraph of Article 8 of the LFPDP. The Data Subject's consent may be revoked at any time by them, without retroactive effect, in accordance with the procedures established later in this Notice for that purpose.

Notwithstanding any provision of this Notice, the Data Subject acknowledges that their consent will not be required for the processing of Personal Data by the Controller or by third parties in any of the cases set forth in Article 10 of the LFPDP.

By providing any type of information, including your personal data, you expressly:

  • Accept the conditions contained in this Privacy Notice.

Accept the conditions contained in this Privacy Notice.

  • Agree that the information you provide may be stored, used and, in general, processed for the purposes indicated, including for commercial and promotional purposes.

Agree that the information you provide may be stored, used and, in general, processed for the purposes indicated, including for commercial and promotional purposes.

  • Grant “THE CONTROLLER” authorization to obtain, compile, store, share, communicate, transmit and use such information in any manner or form, in accordance with the conditions established herein and applicable laws.

Grant “THE CONTROLLER” authorization to obtain, compile, store, share, communicate, transmit and use such information in any manner or form, in accordance with the conditions established herein and applicable laws.

Limitation of use

“THE CONTROLLER” and/or its Processors will retain the Data Subject's Personal Data for as long as necessary to process your requests for information, products and/or services, as well as to maintain accounting, financial and audit records under the terms of the LFPDP and current commercial, tax and administrative legislation, in addition to controlling the disclosure of such data or information from business partners.

Contact

Questions, comments and the exercise of rights to the Personal Data Protection Department of “THE CONTROLLER.”

Email: contacto@grupoibc.mx

Address: Av. Empresarios 255, Torre Icon 23, Puerta de Hierro CP. 45116 Zapopan, Jalisco, Mexico.

“THE CONTROLLER” reserves the right to modify or amend, in whole or in part, this Privacy Notice. The modified Privacy Notice will be sent to the email address you provided to us.

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Failure to object to the new Privacy Notice within the 5 business days following its receipt will be understood as your acceptance of the terms established therein.

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